Mexico's Sectoral Program for Environment and Natural Resources (Programa Sectorial de Medio Ambiente y Recursos Naturales or PROMARNAT) is aligned with the National Development Plan and promotes a sustainable development model based on the principle of "sustainable humanism," which seeks to balance social well-being with environmental protection. Its core pillars include:
- ecosystem restorations
- climate change mitigation and adaptation
- energy transition toward clean sources
- sustainable management of water and other natural resources
- promotion of the circular economy and sustainable waste management
- inclusive environmental governance frameworks
Relevance for the Industrial and Productive Sector
Environmental Regulation
- Under PROMARNAT, increased regulatory requirements are anticipated for the industrial sector, particularly regarding emissions, waste management and the use of natural resources.
- New regulations are also expected in the areas of emissions control, waste disposal and energy efficiency.
- It is foreseeable that inspections will become more stringent and sanctions will be applied in proportion to environmental impact.
- Consequently, industries will be required to adapt their operational processes to comply with updated regulations concerning energy efficiency, water treatment and the handling of hazardous waste.
Incentives and Subsidies
PROMARNAT provides for the granting of temporary subsidies and financial mechanisms to promote the transition toward sustainable practices. These will be channeled primarily through:
- financial instruments for ecological restoration, including mixed funds, trusts and public-private investment schemes
- commutation of environmental fines for equivalent investments in restoration or environmental compensation
- targeted subsidies for productive activities that incorporate sustainability criteria such as community forest management, regenerative agriculture and clean production
- preferential access to federal programs for companies that adopt green technologies, obtain environmental certifications or participate in restoration projects
These supports will be subject to technical evaluation criteria, environmental impact and economic viability, and will be coordinated with entities such as the National Forestry Commission (Comisión Nacional Forestal or CONAFOR), National Institute of Ecology and Climate Change, and Ministry of Environment and Natural Resources (Secretaría del Medio Ambiente y Recursos Naturales or SEMARNAT).
Circular Economy
The program promotes a structural transformation toward a circular economy through:
- the establishment of technical standards and guidelines for eco-design, recycling and the reuse of materials in industrial processes
- the development of regional centers for circular innovation, where technologies, business models and training programs for companies will be created
- the formation of partnerships with the private sector to implement sustainable value chains, particularly in sectors such as food, textiles, plastics and construction
- the granting of fiscal and financial incentives to companies that reduce their environmental footprint through energy efficiency, waste reduction and the use of recycled materials
- the creation of a National Circular Economy System
Sustainable Forest Management
- The Sustainable Forest Development for Well-Being (Desarrollo Forestal Sustentable para el Bienestar) Program seeks to incorporate forested areas into competitive and participatory management schemes.
- Productive restoration will be promoted with a territorial approach, creating specific opportunities for the agro-industrial and forestry sectors.
Environmental Services
PROMARNAT also promotes schemes for payment for environmental services (PES) and ecological compensation, with active participation from the private sector.
- Companies may finance conservation projects in priority areas and receive tax benefits or compensation certificates in return.
- Market-based mechanisms will be established for services such as carbon capture, watershed conservation and biodiversity protection.
- Participation in environmental trusts will be encouraged, allowing industries to invest in restoration efforts and obtain reputational and regulatory returns.
These schemes will be regulated by SEMARNAT and CONAFOR and will be aligned with national and international climate goals.
Implications for Business Planning
PROMARNAT proposes a strategic reconfiguration in the planning processes of industrial and productive enterprises through:
- Climate Risk Assessment. Companies will be required to incorporate climate vulnerability analysis into their investment, infrastructure and logistics planning, which will represent a new challenge for many productive entities.
- Environmental Certifications. The certification framework for products and processes will be strengthened, including green labeling, carbon footprint measurement and traceability standards.
- Community Consultation. Industrial projects will be expected to demonstrate the implementation of free, prior and informed consultation processes with local communities, particularly in rural or indigenous areas.
- Enhanced Regulatory Compliance. As previously noted, an update to the country’s environmental regulations is anticipated, involving more rigorous inspections and sanctions proportionate to the environmental damage caused in cases of non-compliance.
The integration of these variables into corporate planning will minimize regulatory risks and open the door to new and innovative financing opportunities.
Public-Private Collaboration Opportunities
PROMARNAT opens avenues for collaboration among government, private enterprises and civil society through:
- environmental restoration projects in priority areas, with private sector participation in financing, implementation and monitoring
- development of green infrastructure – such as treatment plants, ecological corridors and recycling systems – through public-private partnership (PPP) schemes
- environmental education and training for company personnel, supported by universities, technology centers and business chambers
- technological innovation in energy efficiency, carbon capture, environmental monitoring and waste management
These collaborations will be formalized through agreements, public calls for participation and intersectoral platforms coordinated by SEMARNAT.
Compatibility with the Federal Economic Package 2026 (Presupuesto de Egresos de la Federación or PEF 2026)
To achieve the strategic reconfiguration proposed, PROMARNAT establishes clear objectives and implements mechanisms that will require budgetary allocation. However, when compared to the projected PEF 2026, it becomes evident that not all program components are explicitly covered. Therefore, it cannot be ruled out that certain objectives may be financed through revenues derived from federal sanctioning procedures and the imposition of compensatory measures in accordance with current legislation and any future regulatory developments.
Holland & Knight has the knowledge and experience necessary to advise companies in relation to this new regulatory framework, which will undoubtedly impact their operations. Nonetheless, if properly leveraged, the framework may also represent a new and valuable business opportunity for organizations.
